…annual review is done by someone they occasionally have to investigate.

…isn’t responsible for all elements of a compliance program.

…isn’t responsible for all risk areas.

…can’t investigate something they deem necessary to investigate.

…doesn’t have access to people or information they need access to.

It is tough to get all these things in place. We are going through a progression. It will improve. But it’s misleading to call someone a Chief Compliance Officer if they are not performing the essential elements of the job. You can’t call something a compliance failure if you fail to have an effective Chief Compliance Officer.

It is no different for Internal Audit. “You might not be an internal auditor if…”

…your annual review is completed by the people you audit.

…you don’t have access to the audit committee of the board.

…you can’t report all unresolvable and material audit findings issues to the board.

…you can be prevented from accessing people or information necessary to do your job.

[bctt tweet=”@RoySnellSCCE It’s misleading to call someone a Chief #Compliance Officer if they are not performing the essential elements of the job” via=”no”]

Comments

True observations. Unfortunately our profession is not as funny as Jeff Foxworthy. An insurance executive once told me that in the office they define an actuary as someone who can’t stand the excitement of being an accountant.